Supreme Court: Miranda Warning Not Required for Inmate Questioned About Second Crime in Prison

The U.S. Supreme Court has ruled against a Michigan inmate who contended he should have received a Miranda warning before being interrogated in a prison conference room about sexual conduct with a 12-year-old boy.

The court ruled in a 6-3 opinion (PDF) against inmate Randall Lee Fields, who confessed to molestation while incarcerated on a disorderly misconduct charge. The dissenters were Justices Ruth Bader Ginsburg, Sonia Sotomayor and Stephen G. Breyer.

Fields was told he was free to leave the conference room during the interrogation that lasted between five and seven hours, but he was not given a Miranda warning, according to the majority opinion by Justice Samuel A. Alito Jr.

The Cincinnati-based 6th U.S. Circuit Court of Appeals had ruled that questioning an inmate about events outside of prison is always custodial for purposes of Miranda. “On the contrary,” Alito wrote, “we have repeatedly declined to adopt any categorical rule with respect to whether the questioning of a prison inmate is custodial.”

In this case, Alito said, the circumstances of Fields’ interrogation indicate he was not in custody triggering the need for Miranda warnings. Fields was told he could leave and reminded of the fact. He was also offered food and water, and the door to his conference room was open.

“When a prisoner is questioned, the determination of custody should focus on all of the features of the interrogation,” Alito said. “These include the language that is used in summoning the prisoner to the interview and the manner in which the interrogation is conducted.”